mark.bitterlich(at)navy.m
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 Posted: Fri May 28, 2010 12:31 pm Post subject: Experimental Aircraft AD complience discussion |
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Gents, this included paragraph is the response I got from the EAA
concerning this issue and is EXCELLENT INFO for all of us to keep on
hand. I consider this the last word on the matter IMHO.
Have a great Memorial Day weekend.
Mark Bitterlich
"Concerning the AD concerns and applicability. I understand the points
made in the March 26, 2003 memorandum from the FAA New England Region's
acting regional counsel, however I believe that information is outdated
and no longer applicable. I contacted EAA who in turn contacted the
Manager, Aircraft Maintenance Division, AFS-300 for the current FAA
national guidance on the AD vs. experimental aircraft applicability
issue. The current FAA national policy per Mr. Ron Wojnar, AFS-304, is:
"Existing regulations do not support enforcement of ADs on TC, PMA, and
TSO components installed on non-TCed aircraft. Some ADs may apply to
FAA approved products installed on non-TCed aircraft, but compliance is
not mandatory because the aircraft is not TCed. However, the rules in
part 43 governing the maintenance, preventive maintenance, rebuilding,
and alteration of these aircraft do not apply. The owner or operator of
a non-TCed aircraft is responsible for its design and maintenance.
The FAA encourages owners and operators of these aircraft to comply
with ADs, but the operator may mitigate safety risks in some other way,
without obtaining alternative methods of compliance from the FAA." With
this guidance in mind I do plan on reviewing AD's issued against the
engine and propeller installed on my aircraft to determine their flight
safety applicability per FAR 91.319(b). I will also make the following
logbook entry to indicate that a flight safety determination has been
made: "I certify that AD Number _________________ has been reviewed on
______________(date)."
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